ML12159A613

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Review of 60-Day Response to Request for Information Regarding Recommendation 9.3, of the Near-Term Task Force Related to the Fukushima Daiichi Nuclear Power Plant.
ML12159A613
Person / Time
Site: Browns Ferry, Watts Bar, Sequoyah  Tennessee Valley Authority icon.png
Issue date: 06/08/2012
From: Ellen Brown
Plant Licensing Branch II
To: James Shea
Tennessee Valley Authority
References
TAC ME8619, TAC ME8620, TAC ME8649, TAC ME8650, TAC ME8651, TAC ME8652, TAC ME8653
Download: ML12159A613 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 June 8,2012 Mr. Joseph W. Shea Corporate Manager - Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3, SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2, AND WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 - REVIEW OF 60-DAY RESPONSE TO REQUEST FOR INFORMATION REGARDING RECOMMENDATION 9.3, OF THE NEAR-TERM TASK FORCE RELATED TO THE FUKUSHIMA DAIICHI NUCLEAR POWER PLANT ACCIDENT (TAC NOS. ME8649, ME8650, ME8651, ME8619, ME8620, ME8652 AND ME8653)

Dear Mr. Shea,

By letter dated March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC or Commission) issued a request for information pursuant to Title 10 of the Code ofFederal Regulations (10 CFR),

Section 50.54(f) which included the Near Term Task Force (NTTF) Recommendation 9.3 for Emergency Preparedness (EP). Specifically, licensees were requested to assess their means to power communications equipment onsite and offsite during a prolonged station blackout event and to perform a staffing study to determine the staff required to fill all necessary positions in response to a multi-unit event. If a licensee could not meet the requested 90-day response, then that licensee was required to provide a response within 60 days of the issuance of the letter describing an alternative course of action and estimated completion date.

By letter dated May 11, 2012, the Tennessee Valley Authority submitted its 60-day response for Browns Ferry Nuclear Plant, Units 1, 2, and 3, Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2 proposing an alternative course of action based upon the higher priority to complete the implementation of the revised EP Rule. As discussed in the enclosed NRC staff assessment, the licensee's alternative approach outlined in its 60-day response letter is consistent with Commission direction and is consistent with the guidance in industry document Nuclear Energy Institute (NEI) 12-01, "Guidance for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities." The NRC staff has determined in a letter dated May 15, 2012 (ADAMS Accession No. ML12131A043), that NEI 12-01 is an acceptable approach to responding to the request for information.

In addition, the NRC staff concludes that the licensee provided an adequate basis for its proposed alternative to responding to the 10 CFR 50.54(f) request for information regarding communications and staffing for NTTF Recommendation 9.3.

J.Shea

- 2 Should you have any questions, please feel free to contact me at 301-415-2315.

Sincerely, IRA!

Eva A. Brown, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50- 259,50-260,50-296,50-327, 50-328, 50-390, and 50-391

Enclosure:

Staff Assessment cc w/encl: Distribution via Listserv

NUCLEAR REGULATORY COMMISSION STAFF ASSESSMENT INFORMATION REQUEST MADE UNDER 10 CFR 50.54(f)

REGARDING NEAR-TERM TASK FORCE RECOMMENDATION 9.3 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3, SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2, AND WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-259, 50-260,50-296,50-327,50-328, 50-390 AND 50-391 By letter dated March 12,2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12073A348), the U.S. Nuclear Regulatory Commission (NRC or Commission) issued a request for information pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(f) which included the Near-Term Task Force (NTTF)

Recommendation 9.3 for Emergency Preparedness (EP). Specifically, licensees were requested to assess their means to power communications equipment onsite and offsite during a prolonged station blackout (SBO) event and to perform a staffing study to determine the staff required to fill all necessary positions in response to a multi-unit event. If a licensee could not meet the requested 90-day response, then that licensee was required to provide a response within 60 days of the issuance of the letter describing an alternative course of action and estimated completion date.

By letter dated May 3, 2012 (ADAMS Accession No. ML12125A410), the Nuclear Energy Institute (NEI) submitted NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, May 2012. The NRC staff reviewed NEI 12-01 and found it to be an acceptable method for licensees to use when responding to the NRC's 10 CFR 50.54(f) request for information regarding communications and staffing for EP.

This staff assessment is focused specifically on the licensee's response to the 10 CFR 50.54(f) letters and not on the associated Orders.

By letter dated May 11, 2012 (ADAMS Accession No. ML12136A131), the Tennessee Valley Authority submitted its 60-day response to the 10 CFR 50.54(f) request for information proposing an alternative course of action based upon the higher priority to complete the implementation of the revised EP Rule. The NRC staff reviewed the licensee's proposed alternative against the guidance contained in NEI 12-01. In addition, the NRC staff also considered the direction given by the Commission in the Staff Requirements Memorandum (SRM) to SECY 12-0025, "Proposed Orders and Requests for Information in Response to Lessons Learned from Japan's Enclosure

- 2 March 11, 2011, Great Tohoku Earthquake and Tsunami," dated March 9, 2012 (ADAMS Accession No. ML120690347). This SRM stated, in part, that Completing implementation activities associated with the rule we have already promulgated has greater safety significance and also involves the coordinated actions of our partners in State and local governments. Substantial public credibility benefits accrue from continuing these activities as a priority.

The NRC staff considers the existing EP framework and regulations provide reasonable assurance of adequate protection of public health and safety in the event of a radiological emergency. The revised EP rule that was promulgated on November 23, 2011, initiated a number of activities that will enhance EP programs, including conducting a staffing analysis and enhancing public notification systems. The implementation of the EP rule was given priority by the Commission and the NTTF recommendations should not displace ongoing work that has greater safety benefit, higher priority, or is necessary for continued safe operation of nuclear power plants. The NTIF Report concluded that continued operation and continued licensing activities do not pose an imminent risk to the public health and safety and are not inimical to the common defense and security.

The phased approach to responding to the 10 CFR 50.54(f) letters, combined with the definition of new response requirements associated with Fukushima NTTF Recommendation 4.2, as subsequently modified by the NRC staff and issued as NRC Order EA-12-049 (ADAMS Accession No. ML12054A736), will ensure that enhancements will be made to staffing and communications by licensees. It should be noted that the 10 CFR 50.54(f) letter and implementation of the Order includes completion of actions related to response aSSignments, staffing changes, issuance of new or revised procedures or guidelines, and training. Activities are ongoing by both the NRC and industry to initiate interim actions as a result of lessons learned from the events which will be provided in the 90-day response such as:

Methods to access the site Notification of staff Interim actions taken to date Given the above and that the licensee's approach was found to be consistent with the guidance of NEI 12-01 and the direction of the Commission, the NRC staff concludes that the licensee has provided an adequate basis for its proposed alternative responding to the 10 CFR 50.54(f) letters regarding communications and staffing for Recommendation 9.3.

- 2 Should you have any questions, please feel free to contact me at 301-415-2315.

Sincerely, IRA!

Eva A. Brown, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket Nos. 50- 259, 50-260, 50-296, 50-327, 50-328, 50-390, and 50-391

Enclosure:

Staff Assessment cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsAcrsAcnw _MaiICTR Resource RidsNrrDorlLpl2-2 Resource RidsNrrDorlLp_WB Resource RidsNrrLABClayton Resource RidsNrrPMBrownsFerry Resource RidsNrrPMSequoyah Resource RidsNrrPMWattsBar Resource RidsNsirDpr Resource RidsOgcRp Resource RidsRgn2MailCenter Resource CMurray, NSIR JShea, JLD JKratchman, JLD ADAMS Accession No.: ML12159A613

  • Concurrence via email OFFICE LPL2-2/PM LPL2-2/PM LPL-WB/PM LPL2-2/LA NSIRlNRLB/BC*

NAME EBrown EBrown for Slingam FLyon for JPoole BTuily for BClayton KWilliams DATE 06/8/12 06/8/12 06/8/12 06/8/12 06/6/12 OFFICE NRRlJLD/BC LPL-WB/BC LPL2-2/BC NAME RPascarelli SCampbell DBroaddus DATE 06/8/12 06/8/12 06/8/12 OFFICIAL RECORD COpy